ACCEPTED
14-14-00224-CV
FOURTEENTH COURT OF APPEALS
HOUSTON, TEXAS
2/17/2015 3:35:45 PM
CHRISTOPHER PRINE
CLERK
NO. 14-14-00224-CV
FILED IN
14th COURT OF APPEALS
IN THE FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS
HOUSTON, TEXAS 2/17/2015 3:35:45 PM
CHRISTOPHER A. PRINE
Clerk
PRABHAKAR GUNIGANTI, INDIVIDUALLY, ET AL.
APPELLANTS,
V.
C&S COMPONENTS COMPANY, LTD.,
APPELLEE.
ON APPEAL FROM THE 80TH JUDICIAL DISTRICT COURT
HARRIS COUNTY, TEXAS
HON. LARRY WEIMAN, JUDGE PRESIDING
APPELLANTS’ UNOPPOSED FIRST MOTION
FOR EXTENSION OF TIME TO FILE APPELLANT’S REPLY BRIEF
TO THE HONORABLE COURT OF APPEALS:
Appellants, Prabhakar Guniganti, Individually, The Guniganti Children’s 1999
Trust, and Triple PG Sand Development, LLC, file this Unopposed First Motion for
Extension of Time to File Appellants’ Reply Brief.
1. The deadline for filing Appellants’ Reply Brief is February 19, 2015.
2. This is appellants’ first motion for extension of time to file their reply
brief.
3. Appellants request an extension of 21 days; that is, an extension of time
to and including March 12, 2015.
4. Counsel could not prepare Appellants’ Reply Brief by the current due
date, given proper standards of representation, because of her work in the following
matters:
a. Conducting the research and drafting post-judgment motions, and
analyzing proposed Findings of Fact and Conclusions of Law, in Kyu Im Robinson v.
Jess L. Mayfield, et al.; Cause No. 2013-CI-07766; in the District Court of Bexar
County, Texas, 131st Judicial District. The trial court’s judgment in that case was
signed on February 3, 2015.
b. Assisting in the research and drafting of Appellant’s Reply Brief
in No. 01-14-00317-CV, Pelco Construction Co. v. Chambers County, Texas, in the
First Court of Appeals, Houston, Texas. The brief in that case was filed on February
12, 2015.
c. Assisting in the research and drafting of Reply to Respondents’
Joint Response to Petition for Review in No. 14-0656; MBI Global, L.L.C. v. Hunter
Buildings & Manufacturing, L.P., et al.; in the Supreme Court of Texas. That reply
was filed on February 3, 2015.
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5. Counsel would show that she is a solo practitioner and is solely
responsible for the work necessary to prepare Appellants’ Reply Brief in this case.
PRAYER
For the reasons stated, appellants request that this Court grant this motion and
extend the time for filing Appellants’ Reply Brief to and including March 12, 2015.
Respectfully submitted,
JOANN STOREY, P.C.
BY: /s/ JoAnn Storey
JoAnn Storey
State Bar No. 19315300
1005 Heights Boulevard
Houston, Texas 77008
Telephone: 713/529-0048
Facsimile: 713/529-2498
Email: storeyj@heightslaw.com
Attorney for appellants,
Prabhakar Guniganti,
Individually, The Guniganti
Children’s 1999 Trust, and
Triple PG Sand Development,
LLC
CERTIFICATE OF CONFERENCE
Counsel for appellee does not oppose this motion.
/s/ JoAnn Storey
JoAnn Storey
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CERTIFICATE OF COMPLIANCE
Relying on the word count function in the word processing software used to
produce this document, I certify that the number of words in this motion is 541.
This motion complies with the typeface requirements of TRAP 9.4(e) because
it uses a conventional typeface no smaller than 14-point (WordPerfect X4 14-point
Times New Roman).
/s/ JoAnn Storey
JoAnn Storey
CERTIFICATE OF SERVICE
On February 17, 2015, I sent a true and correct copy of the foregoing
Appellants’ Unopposed First Motion for Extension of Time to File Appellants’ Reply
Brief via EFILE to the following:
Dylan B. Russell
HOOVER SLOVACEK LLP
5051 Westheimer, Suite 1200
Houston, Texas 77056
Attorneys for appellee,
C&S Components Company, Ltd.
/s/ JoAnn Storey
JoAnn Storey
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